Sanborn v. Commissioner
United States Board of Tax Appeals
An insurance agent's contract with his company allowed him all commissions on policies written in territory assigned him, but required him to organize such territory, write insurance, employ, train and supervise the work of subagents therein, whose commissions were paid by him, all of which he did.
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An insurance agent's contract with his company allowed him all commissions on policies written in territory assigned him, but required him to organize such territory, write insurance, employ, train and supervise the work of subagents therein, whose commissions were paid by him, all of which he did. His net commissions were in each taxable year in excess of $20,000. Held, petitioner was entitled to claim in each taxable year $20,000 as earned net income for personal services actually rendered.
1Opinion of the Court
*497OPINION.
Sea well:
The deficiencies in question are for the years 1925 and 1926 and the applicable law is found in the Revenue Act of 1926 (which by section 286 thereof is made effective as of January 1, 1925), as follows:
Sec. 209. (a) For the purposes of this section—(1) The term “ earned income ” means wages, salaries, professional fees, and other amounts received as compensation for personal services actually rendered, * ⅞ ⅝. In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income producing factors, a reasonable allowance as…
2Cited by4 opinions
- Miller v. CommissionerUnited States Tax Court · 1969
- District of Columbia v. Joseph E. Jones and Marjorie B. Jones, T/a Joseph E. Jones AgencyCourt of Appeals for the D.C. Circuit · 1959
- Miller v. CommissionerUnited States Tax Court · 1969
- Sanborn v. CommissionerUnited States Board of Tax Appeals · 1930